Your Profile with us
It is essential to us to only select Talent Partners whose values align with ours. To do this we build a profile about you to check our values align and that the L’Oréal products you are interested in match our promotion plans. This involves us taking a look at your social media content and public profile to see if our values match (i.e. respect, tolerance, inclusion). The profile we build about you includes the information captured through our channel review and the information we know about you through your relationship with us, i.e, campaigns you have been part of and our history of working together (‘Your Profile’).
We collect this information from different sources depending on how we engage with you – be it as a contracted Talent Partner or as someone who has mentioned our products online and we are considering as a Talent Partner - a Potential Talent Partner. We collect the information from: you (including questionnaires or surveys you, or your agent acting on your behalf, complete such as our Beauty Profile questionnaire), other L’Oréal Group companies, your agent, a third-party agency working on our behalf including an Affiliate Marketing Platform, our own knowledge and understanding, media coverage, as well as publicly available information such as via your social media account or that of another person or organisation (for example, when you mention L’Oréal products or services on non-L’Oréal pages such as social media platforms or third party agencies).
We also use personal data we gather through Cookies and similar technologies (for example, using cookies or built-in disclosure tools on platforms, such as Instagram's Paid Partnership tool, to understand social media reach and engagement) to enrich Your Profile. Sometimes we require your consent to ‘drop’ the cookie and collect this information – for more information about how we use cookies, please see our cookie policy on our different Brand websites and our Consumer Privacy Policy.
The personal data we use includes: your name, Handle, nickname, birthday or age range, gender, details of an organisation you represent, professional and/or personal email, phone number, and professional and/or personal address, any ID documentation that has been shared with us, images, your preferences (including language preference, products of ours you love or we think suit you), your video, photo, post and/or other content posted to social channels (including: Instagram, Facebook, Twitter, TikTok, Snapchat, YouTube or Google+), blog posts, your social media handle, social media username, profile picture, caption and location information you may have included in your content and your User Generated Content. If we both agree to work together, continue to develop it to maintain that analysis and keep it up to date to best manage our relationship with you and for other purposes explained in this section.
We may also include sensitive personal data in Your Profile, such as your race, ethnicity, religion, and health information. This will always be collected from you, from your agent acting on your behalf, or from another publicly confirmed source. We use this information to support our ambition to be a diverse and inclusive company whose campaigns and Talent Partners reflect society as a whole. Please also see the ‘Note on sensitive personal data’ section below.
Legitimate business interests - We use Your Profile where it is in our legitimate interests to do so. This includes:
- To improve our products and services and how we engage with our consumers and customers, and they with us – for example, understanding your interactions with them in turn helps us understand our social reach;
- to build Your Profile and better engage with you in your role as a Talent Partner and/or a Potential Talent Partner including sending you products, product surveys and information about upcoming and existing products, checking your previous and each new post you make online to ensure our values are, and remain, aligned (our ‘Values Charter’ check);
- to manage and develop our Talent Partner strategy, understanding what works well and what doesn’t so we continuously improve our approach;
- to secure, improve and protect: our brands, our consumer and customer trust, develop our Talent Partner strategy and our products, services, tools, infrastructure, websites and platforms; and
- to prevent fraud or criminal activity (for example, to ensure you do not buy or artificially inflate your follower account e.g. via “paid-for” or “like-for-like” means).
Our Values Charter and Your Profile – our use of automated decision making
We use your publicly available personal data to check our values are aligned. Such checks consist of us (or a trusted partner of ours) assessing Your Profile (see above) to ensure they align with our Values Charter. We evaluate your public social profiles and publicly available information, to assess and predict your behaviour and understand its impact on us such as your suitability for campaigns we are working on now or in the future. We use an algorithm to carry out our values matching analysis, our personnel then review all values match profile output.
Relationship management
We also use the personal data we hold in the profile we build about you (see above) to enter into and/or fulfil our contractual obligations where we have an agreement with you. This includes any relationship management communications between us and your agent and/or our agent, paying you, arranging meetings and liaising with your agent and our agent, where applicable.
We may also use Your Profile to invite you to events, seminars and training sessions and share information about our strategy, products and services. We do this as it is in our legitimate business interests to maintain an engaged Talent Partner pool, and where it is part of the contractual terms we have agreed for you to represent us at such events. We may also do this if you are a Potential Talent Partner too. This may involve us needing to share your personal data with a supplier acting on our behalf or another third party who is hosting the event.